Justia Civil Rights Opinion Summaries

Chinyere Ogbonna-McGruder, an African American professor, alleged that her employer, Austin Peay State University (APSU), and her supervisors engaged in racial discrimination and created a hostile work environment, and retaliated against her when she opposed their unlawful conduct. She also claimed that her supervisors violated her constitutional rights under 42 U.S.C. § 1983. The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision to dismiss all counts for failure to state a claim. The court ruled that Ogbonna-McGruder failed to sufficiently allege that the harassment she experienced was severe or pervasive, a necessary element of a hostile work environment claim. The court also found that she did not sufficiently allege that any adverse employment actions were motivated by discriminatory animus, and that she did not adequately assert that the conduct forming the basis of her §1983 claim violated a specific constitutional provision. View "Ogbonna-McGruder v. Austin Peay State Univ." on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, Leslie Fisher sued officers Randall Jordan, Matthew Rice, and John Trefelet of the Michigan State Police for violating federal and state law by arresting her without probable cause. Fisher and her husband were arrested after the officers executed a search warrant and found marijuana growing in their garage. All charges against Fisher were eventually dismissed in state court. She then filed a federal lawsuit against the arresting officers.The officers moved for summary judgment, invoking qualified immunity in response to Fisher's federal claims of arrest and prosecution without probable cause under 42 U.S.C. § 1983, and governmental immunity for her state claims of false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment to the officers, concluding that they had probable cause to arrest Fisher.On appeal, the Sixth Circuit affirmed the district court's decision. The court found that the officers had probable cause to believe that Fisher had committed the crime of possession of at least 5,000 grams of marijuana with the intent to distribute, based on various pieces of evidence. This included the fact that Fisher lived at and owned the site of the marijuana cultivation operation, and that she admitted to using marijuana grown by her husband. The court also found that the large quantity of marijuana in the Fishers' garage supported probable cause to infer intent to distribute.The court further concluded that the officers were entitled to governmental immunity from Fisher's state law claims, as the probable cause analysis for federal Fourth Amendment claims is the same under Michigan law. Since the officers had probable cause to suspect that Fisher possessed an illegal quantity of marijuana with the intent to distribute, they were entitled to governmental immunity from Fisher's state law claims. View "Fisher v. Jordan" on Justia Law

In this case, Timmy Mosier, a man arrested for public intoxication, brought federal civil rights and state tort claims against Officer Joseph Evans and Crockett County, Tennessee. Mosier alleged that Officer Evans used excessive force resulting in serious injury when he pulled Mosier to the ground causing him to hit his head. The United States Court of Appeals for the Sixth Circuit held that Officer Evans was entitled to qualified immunity on Mosier's federal excessive-force and inadequate-medical-care claims because Mosier failed to demonstrate that Evans violated a clearly established statutory or constitutional right. The court also affirmed the grant of summary judgment in favor of Crockett County on Mosier's federal municipal-liability claim, finding that Mosier failed to show that a municipal policy or custom caused the alleged violation of his rights. The court also affirmed the dismissal of Mosier's state-law negligence claims against Evans in his official capacity and against Crockett County under the Tennessee Governmental Tort Liability Act's civil-rights exception. However, the court reversed the dismissal of Mosier's negligence claim against Evans in his personal capacity. View "Mosier v. Evans" on Justia Law

In the case involving a high school student, Jacob Bradley, and his parents, the United States Court of Appeals for the Sixth Circuit concluded that the Individuals with Disabilities Education Act (IDEA) does not require states to provide special education services to students participating in dual-credit or dual-enrollment programs offered at postsecondary institutions.Jacob Bradley, a gifted student with several physical and cognitive conditions, was enrolled in the Craft Academy for Excellence in Science and Mathematics, a state-run dual-credit program located at Morehead State University. His parents sought reimbursement for special education support accommodations provided at Craft under IDEA. However, the district court ruled that IDEA, which offers federal funds to states to provide free appropriate public education to students with disabilities, does not apply to Craft because its dual-credit classes provide postsecondary rather than secondary school education.The Court of Appeals affirmed this decision, holding that the IDEA’s obligation to provide a "free appropriate public education" applies to "secondary," not postsecondary, education. The court also noted that, under Kentucky law, Craft is considered a postsecondary school because it delivers a college-level course of study on a college campus.The court also concluded that the state and federal agencies' interpretation of the IDEA and the state law, which excluded dual-credit courses at postsecondary institutions from IDEA’s mandate, was correct. The court emphasized that the IDEA is a spending clause legislation that operates as a contract between the federal government and states, and states need to comply only with clearly written terms in the Act, not uncertain or ambiguous ones.Additionally, the court affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, as they failed to demonstrate how the Commonwealth separately violated the provisions of these distinct Acts.In conclusion, the court held that the IDEA does not obligate Kentucky school districts to provide special education services to a student participating in dual-credit classes offered at a postsecondary institution. The court also affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. View "Bradley v. Jefferson Cnty. Public Schs." on Justia Law

In this case heard before the United States Court of Appeals for the Sixth Circuit, the plaintiff, Christina Littler, a bus driver for a school district, appealed a grant of summary judgment in favor of the defendant, Ohio Association of Public School Employees (OAPSE), a union she had joined. Littler had filed a 42 U.S.C. § 1983 action alleging the wrongful deduction and retention of union dues. She claimed that she had withdrawn her union membership and therefore her dues deduction authorization too, but OAPSE had continued to deduct dues from her paycheck. On remand from an earlier appeal, the district court held that Littler had failed to show that OAPSE was a state actor under § 1983, and thus granted OAPSE summary judgment on Littler’s § 1983 claim.The Sixth Circuit affirmed the district court’s judgment. It held that Littler had failed the first prong of the "state action" test under § 1983, as she could not show that the alleged deprivation was caused by any governmental policy or decision. Instead, the conduct she complained about was inconsistent with the collective bargaining agreement and violated her agreement with OAPSE. This conduct was attributed to a private actor—OAPSE—acting contrary to any rule of conduct imposed by the state, and therefore could not be attributed to the state. The court also rejected Littler's argument that the deprivation was caused by the terms of the collective bargaining agreement and the school district’s compliance with the union’s request to withhold dues from her paycheck. Instead, the court held that the specific conduct complained about was OAPSE’s failure to process Littler’s withdrawal pursuant to the membership application and remove her name from the deduction list. This was not governed by a state-imposed rule of conduct but rather by a private individual or organization’s policy. Thus, the court concluded that the challenged conduct could not be fairly attributable to the state. View "Littler v. Ohio Ass'n of Pub. Sch. Emps." on Justia Law

In this case, a prisoner named Lyle Heyward filed a complaint alleging that prison officials frustrated his attempts to celebrate Ramadan, a holy month for Muslims, in violation of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). He also alleges that officials retaliated against him for filing grievances in violation of the First Amendment. The United States Court of Appeals for the Sixth Circuit affirmed the dismissal of Heyward’s Religious Land Use and Institutionalized Persons Act (RLUIPA) claim, as RLUIPA does not permit money damages claims against state prison officials in their individual capacities, and his requests for injunctive relief were mooted by his transfer to a different prison facility.However, the court reversed the dismissal of Heyward’s First Amendment retaliation claim against Defendant Guise, finding that Heyward had adequately pleaded a retaliation claim. Specifically, Heyward alleged that after he filed a grievance against Guise, she threatened members of the Cultural Awareness Inmate Group to kick Heyward out of the organization or else the organization would be shut down. The court found these allegations sufficient to suggest that Guise's action was motivated at least in part by Heyward’s grievance-filing.The court also reversed the dismissal of Heyward’s Equal Protection Clause claim against Defendants Cooper, Smith, Davis, and Factor. Heyward alleged these officials treated members of other faith traditions differently than they treated Muslims. The court found that Heyward’s allegations of a facially discriminatory distinction between different religious groups sufficiently alleged an equal-protection violation.The case was remanded for further proceedings. View "Heyward v. Cooper" on Justia Law

This case concerns Ana Sanchez Sebastian-Sebastian, a native and citizen of Guatemala, who appealed the denial of her application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) by the Board of Immigration Appeals (BIA). The United States Court of Appeals for the Sixth Circuit found that the BIA did not fully consider whether Sebastian-Sebastian was persecuted due to her membership in certain social groups, including "Guatemalan Chuj Women in domestic relationships who are unable to leave" and "Guatemalan Chuj Women who are viewed as property by virtue of their positions within a domestic relationship." The court noted that the BIA ended its analysis prematurely, failing to consider the possibility that Sebastian-Sebastian's persecutors may have had mixed motives for their persecution. The BIA also failed to consider whether her husband's motives were intertwined with her particular social groups. As a result, the court granted Sebastian-Sebastian's petition for review in part, vacated the BIA's denial of her application for asylum and withholding of removal, and remanded the case to the BIA for reconsideration. However, the court denied Sebastian-Sebastian's petition for review regarding her CAT claim and dismissed her due process claim, finding that her right to due process was not violated. View "Sebastian-Sebastian v. Garland" on Justia Law

Bradley Peterson, a former professor at Ohio State University, claimed his procedural-due-process rights were violated when the university stripped him of his emeritus status without adequate process. Following a sexual harassment complaint against him, the university conducted an investigation, concluded that Peterson violated the university's Sexual Misconduct Policy, and subsequently revoked his emeritus status. Peterson argued that he had a property interest in his emeritus status and its related benefits. The United States Court of Appeals for the Sixth Circuit, however, affirmed the district court's decision to dismiss Peterson's complaint. The court held that Peterson failed to establish a constitutionally protected property interest in his emeritus status. The court noted that emeritus status was an honorific title, and Peterson did not show that he lost pay or tangible benefits from Ohio State when his emeritus status was revoked. The court also noted that Peterson's claim of harm to his professional reputation was akin to a liberty interest claim, and he did not request a name-clearing hearing, which was a prerequisite for asserting such a claim. View "Peterson v. Johnson" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Rudolph Betancourt, a disabled individual, filed a lawsuit against Indian Hills Plaza LLC, the owner of a shopping plaza, citing violations of the Americans with Disabilities Act (ADA). The plaintiff experienced difficulties accessing the shopping plaza due to his disability. The parties agreed that the defendant had violated the ADA in 17 aspects, and Indian Hills Plaza LLC undertook remediation measures. The district court awarded Betancourt $12,000 in attorney's fees and costs. However, Betancourt appealed this decision, believing he was entitled to more.The main issue on appeal was the challenge to the district court's award of attorney’s fees and costs. The Court of Appeals affirmed the District Court's decision, finding no abuse of discretion. The court explained that the district court properly calculated the lodestar amount (reasonable hourly rate multiplied by the reasonable number of hours worked), which serves as a baseline for attorney's fees. It reduced the hourly rate considering the quality of the performance of Betancourt’s attorney and reduced the number of hours billed by 20% due to excessive billing. The court further reduced the attorney’s fees award based on deficiencies in the actions by Betancourt’s counsel during the litigation. The district court also deemed the requested expert costs as unreasonable and reduced them.Therefore, the holding of the case is that the district court did not abuse its discretion in awarding $12,000 in attorney’s fees and costs to the plaintiff, and that the court properly calculated the lodestar amount and adjusted it based on relevant considerations. The court also held that the plaintiff's attorney's premature fee motions, not the defendant's opposition to those motions, caused the excessive fees. View "Betancourt v. Indian Hills Plaza LLC" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Marlean Ames, alleged that the Ohio Department of Youth Services discriminated against her on the basis of sexual orientation and sex under Title VII of the Civil Rights Act of 1964. Ames, a heterosexual woman, was an employee of the Department and was demoted from her position as Administrator of the Prison Rape Elimination Act, and denied a promotion to Bureau Chief of Quality. She was replaced in her role by a gay man and the Bureau Chief position was filled by a gay woman.The court affirmed the district court's grant of summary judgment in favor of the Department. It found that Ames failed to provide sufficient evidence of "background circumstances" necessary to establish a prima facie case of discrimination based on sexual orientation. The court stated that a plaintiff who is a member of the majority must show suspicion that the defendant is an unusual employer who discriminates against the majority. Ames was unable to provide evidence that the decision-makers who demoted her were part of a minority group (gay people) or that there was a pattern of discrimination against heterosexuals by the Department.As for Ames's sex discrimination claim, the court found that while Ames was replaced by a man, the Department had provided nondiscriminatory reasons for her demotion. The Department cited the need for improved performance and the fact that Ames's evaluations showed she met expectations rather than exceeded them. Ames was unable to show that the Department's reasons were without basis in fact, did not actually motivate the employer's actions, or were insufficient to motivate the employer's actions. Therefore, her claims of pretext were not persuasive. View "Marlean Ames v. Ohio Dep't of Youth Servs." on Justia Law